Transfer Pricing Compliance
Documentation, benchmarking, and arm's-length pricing for intercompany transactions — aligned with OECD BEPS and local regulations across OHADA jurisdictions.
Book a TP AssessmentTransfer Pricing in Africa — Getting It Right
Transfer pricing regulations are expanding rapidly across Sub-Saharan Africa as tax authorities align with OECD BEPS Action 13. A growing number of OHADA and East African jurisdictions now enforce specific transfer pricing rules — with documentation obligations and penalty regimes for non-compliant related-party transactions.
ValidWave prepares contemporaneous transfer pricing documentation (Local File / Master File where required), benchmarking studies using comparable data, and assists with disclosures required in annual tax returns.
Transfer Pricing Services
Local File Preparation
Contemporaneous documentation of controlled transactions — functional analysis, characterisation, and arm's-length benchmarking for each material intercompany flow.
Benchmarking Studies
Comparable uncontrolled price (CUP) and comparable profit method (CPM) analyses using regional databases to establish arm's-length ranges for your transactions.
Intercompany Agreements
Drafting of intercompany service agreements, management fee arrangements, and loan agreements aligned with the transfer pricing policy and supported by benchmarks.
Country-by-Country Reporting
CbCR preparation for groups meeting the revenue threshold, filed in the ultimate parent jurisdiction and notified in each operating country as required by local rules.
TP Risk Assessment
Review of existing intercompany pricing against current local rules to identify documentation gaps and pricing risks before a tax authority challenge arises.
Audit Defence
Technical support and representation during transfer pricing audits — preparing responses, supplementary benchmarking, and negotiating settlements with tax authorities.
TP Rules by Jurisdiction
- DRC — Loi des Finances provisions on related-party transactions; documentation required for transactions exceeding USD 500K with related non-resident entities
- Cameroon — Article 19 bis CGI; annual TP declaration Form C15 for large taxpayers; DGI increasingly scrutinising management fees
- Rwanda — Income Tax Law Art. 30; RRA has issued TP guidelines; documentation required for transactions with non-resident associates
- Senegal — Code Général des Impôts Art. 17; documentation obligation for transactions > XAF 100M with related parties
- Côte d'Ivoire — Code Général des Impôts Art. 18 bis; contemporaneous documentation required for all significant related-party transactions